Case Digest (G.R. No. 104768) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Republic of the Philippines vs. Sandiganbayan, Major General Josephus Q. Ramas and Elizabeth Dimaano (G.R. No. 104768, July 21, 2003), petitioner PCGG sought forfeiture of properties allegedly accumulated by retired Commanding General Ramas and his aide-typist/mistress Dimaano under R.A. 1379. After President Aquino issued E.O. No. 1 creating the PCGG to recover “ill-gotten wealth” of the Marcos circle, its AFP Anti-Graft Board investigated Ramas’s unexplained wealth. On July 27, 1987, the Board found Ramas and Dimaano in possession of P2,870,000 and US$50,000, military and communication equipment, jewelry and land titles, recommending prosecution under R.A. 3019 and R.A. 1379. On August 1, 1987, PCGG filed a forfeiture petition with the Sandiganbayan; an Amended Complaint impleaded the Republic as plaintiff, Ramas as defendant and Dimaano as co-defendant. Ramas denied ownership and Dimaano claimed lawful possession of the seized items. After protracted pre-trial troubles mar Case Digest (G.R. No. 104768) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Creation of PCGG and AFP Board
- After EDSA Revolution, President Aquino issued EO No. 1 creating the PCGG to recover ill-gotten wealth of Marcos, relatives, subordinates and close associates; vested PCGG with investigative and rule-making powers.
- PCGG formed an AFP Anti-Graft Board for unexplained‐wealth probes of AFP officers; on 27 July 1987, the AFP Board issued a resolution finding Major Gen. Ramas had ill-gotten wealth (properties, equipment, cash) in collusion with Elizabeth Dimaano and recommended forfeiture proceedings under RA 3019 and RA 1379.
- Forfeiture petition and Sandiganbayan proceedings
- On 1 August 1987, PCGG filed a civil forfeiture petition under RA 1379 naming Ramas and, via amended complaint, the Republic (PCGG) as plaintiff and Dimaano as co-defendant. Ramas and Dimaano answered and asserted defenses and counterclaims.
- After pretrial, the Sandiganbayan set trial for November 1988, postponed to April 1989; petitioner repeatedly asked postponements and filed motions to amend. Between 1989–1990, PCGG presented only three witnesses, then manifested inability to proceed, sought leave to amend, and failed to complete evidence despite multiple court extensions. Private respondents moved to dismiss based on Migrino and Cruz precedents.
- Sandiganbayan resolutions
- On 18 November 1991, the Sandiganbayan dismissed the amended complaint for want of jurisdiction and prima facie evidence, ordered return of confiscated items to Dimaano, and referred records to the Ombudsman and Bureau of Internal Revenue.
- On 25 March 1992, the Sandiganbayan denied PCGG’s motion for reconsideration.
Issues:
- Whether the PCGG had jurisdiction to investigate and file a forfeiture petition against Ramas and Dimaano under EO 1 (and its amendments) in relation to RA 1379.
- Whether the Sandiganbayan erred in dismissing the case before PCGG completed presentation of its evidence.
- Whether the seizure of monies, communications equipment, jewelry and land titles—items not listed in the search warrant—was lawful or whether such items should be excluded and returned.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)